Polar Technology Responds to the EPA's Rule on HCFC Allocations

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Ted Atwood, President at Polar Technology, summarizes and responds to EPA's proposed rule.

Polar Technology confirmed that on December 5, Administrator Gina McCarthy from the Environmental Protection Agency (EPA) released a proposed rule seeking feedback on three options for determining HCFC-22 allocation from 2015 through 2019. The EPA is required by the Montreal Protocol and section 608 of the Clean Air Act to phase out all production of HCFC chemicals such as R-22 by 2030. HCFC-22 is used in commercial and residential equipment such as air conditioners and refrigeration equipment, and causes harmful effects to the ozone layer if released or leaked into the air.

The EPA's preferred option is a five year linear drawdown, decreasing the allocation by the same amount each year from 2015 through 2019. Under this option, the EPA would start with the lowest possible allocation amount of approximately 36 million pounds in 2014, reducing the allocation to 30 million pounds in 2015, 24 million pounds in 2016, 18 million pounds in 2017, 12 million pounds in 2018, 6 million pounds in 2019, and ending at zero pounds in 2020. The EPA believes that this option is the best approach to drive necessary change in the service market to prepare for the 2020 deadline without unnecessarily forcing retrofits on HCFC-22 equipment that is still within its life expectancy. The EPA also mentioned that this option allows service technicians to explain the phaseout to home and business owners in an easier-to-understand manner.

The second option on the table is a three year linear drawdown, where consumption is phased out by 2018 instead of 2020. The benefits of this option would be to increase the incentive to recover and recycle HCFC-22 two years sooner, to encourage the replacement of older less energy efficient equipment, and to put less stress on the environment. However, this option would also require an efficient system to be put into place much faster, leaving more room for error and rushed judgment.

The final option is an estimation approach, where the EPA will estimate servicing need using the Vintaging Model, making adjustments to account for estimated recovery, reuse, and inventory.

Ted Atwood, President of Polar Technology stated, "There is a lot of posturing around the allocations for the 2015-2020 period as people and companies attempt to manage their investments and plan for what is to come. This issue will affect every American, within the next 5 years. That's why we are already prepared for the final rule by the EPA, because with 19 years of experience in this industry we are already positioned to help our customers succeed in this environment."

A copy of the proposed rule is available at http://www.epa.gov/ozone/downloads/2015-2019_HCFC_Proposed_Rule_Pre-publication_version_12-5-13.pdf.

About Polar Technology
For the past 19 years, Polar Technology has provided refrigerant life-cycle management solutions to companies and individuals who are focused on the importance of managing the ecologicalimpact of their refrigerants. Polar offers its customers the ability to manage the entire refrigerant lifecycle process through a single vendor by implementation of responsible management practices (recovery, recycling, and most importantly tracking with audit support). Polar saves customers money by controlling and protecting the integrity of the entire handling process, and by eliminating opportunities for costly emissions or corrupt data. Polar also streamlines the management and compliance reporting process through the use of their own TrakRef software platform. Polar is the leader in the refrigerant reclaim and management marketplace with plant locations in Nashville, Tennessee, Ontario, California, and Puerto Rico.

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Brad Halford
since: 06/2010
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